SOLAR SUPPLY CHAIN TRACEABILITY PROTOCOL 1.0 INDUSTRY GUIDANCE

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INTRODUCTION
Transparency of supply chains is paramount. Equipment purchasers, electricity end-users, and other stakeholders demand transparency for reasons ranging from sustainability to corporate social responsibility to import compliance. In this environment, manufacturers must have the proper systems in place to meet stakeholder needs and build trust. To assist the industry, SEIA, with the support of Clean Energy Associates (CEA) and Senergy Technical Services (STS), has developed this Solar Supply Chain Traceability Protocol 1.0 (Protocol) to help manufacturers and importers demonstrate the provenance of their products by developing and implementing a traceability program consistent with the general principles herein.

SCOPE
The Protocol is intended to have universal application across product lines intended for export to the U.S. market.Key adopters of the Protocol will include:
• Equipment manufacturers; and
• U.S. importers.
While the Protocol focuses on the provenance of material inputs, it also recognizes the importance of independent, third-party audits and a strong corporate social responsibility and import compliance platform. In assessing conformance, auditors shall apply a holistic approach which recognizes an organization’s unique business processes. No single factor will be dispositive.

TERMS AND DEFINITIONS
Accountability – State of being answerable for decisions and activities to the organization’s governing bodies, legal authorities, and, more broadly, its stakeholders. Documentation – Documents and attestations sufficient to generally establish place and date of manufacture
and/or transfer of goods. Due diligence – A comprehensive, proactive process to investigate, appraise, or evaluate a product or organization. Due diligence is conducted to identify the actual and potential consequences of an organization’s decisions and activities over the entire life cycle of a project or organizational activity, with the aim of avoiding and mitigating negative impacts.

DRIVERS FOR TRANSPARENCY IN THE SUPPLY CHAIN GENERAL
The motivations of organizations for practicing transparency in the supply chain differ depending on the type of organization and the context in which they operate. Drivers for transparency should be analyzed to help define the transparency objectives and goals for the supply chain and to aid internal communication. This section provides examples of drivers for the implementation of a transparency system in the supply chain.

MANAGEMENT OF TRANSPARENCY IN THE SUPPLY CHAIN RISK APPROACH
One key to establishing a robust supply chain transparency system resides in addressing risk – both internal and external. Risk management should therefore be integrated in the decisional and operational activities and conducted in a dynamic, iterative, and responsive manner.

The organization should identify, prioritize, and address risks to increase its resilience to events which can impede product traceability. This includes considering how suppliers are capable of meeting traceability requirements such as monitoring and auditing. It is recommended that the organization conduct an initial review to create a baseline of the risks and opportunities in relation with its products’ traceability.

INTEGRATION OF TRANSPARENCY INTO MANAGEMENT SYSTEMS CONTEXT
The organization should consider product traceability as a priority issue, internally and externally, in its contextual analysis. Stakeholders should be identified and engaged, and information relevant to material provenance monitored and reviewed.

INTEGRATION OF TRANSPARENCY INTO OPERATIONAL PROCESSES PRODUCT DEVELOPMENT
The organization should factor traceability considerations into the product design process.

SUPPLY CHAIN MAPPING
The organization should be able to present a description of the entities involved in creating the product that is being imported. This description can include an illustration of the links in the supply chain in a step-by-step flow from raw materials to finished goods, i.e., supply chain map. While the map can take many forms, the essential elements of a map are illustrated here:

The map should identify individual steps in the process and each step should include information about that step’s entity, such as the item being produced, a description of the overall manufacturing process(es) being employed, the name of the producer, and the location of production. In the case of multiple suppliers of the same item, the map would indicate multiple entities. In the event there are multiple production locations for an entity that are in the supply chain for the final product, the relevant locations should be identified.

Each time there is a transaction between steps in the supply chain, the importer should disclose the nature of the document that codifies the transaction, i.e., a purchase order, supply contract, etc., as well as identify the business unit of the individual who places the order.
Complex products and products with many components or suppliers can lead to complex supply chain maps. These can be simplified by addressing raw materials or intermediate items that are of particular importance, either because of location, cost, uniqueness of the time, or other factors. A more detailed map is illustrated here:

If wafers from different logs are combined, then a new and unique identifier should be assigned to the mixed batch and the provenance of the wafers in the batch should be linked to the batch identifier.

In short, for a pallet of wafers, perhaps identified only by a unique pallet number, the purchaser of the wafers should be able to trace the provenance back to a specific ingot or ingots.

RELEASE OF PRODUCTS
The organization should integrate traceability and security requirements into its product releasing process. The release process should include, as a minimum:
• Availability of traceability information for the products to be shipped;
• Correct identification of the product;
• Where applicable, serialization of the materials;
• Integrity of the products packaging;
• Presence and condition of security elements, including where applicable, transportation seals; and
• Documentary review of logistic documentation including bill of lading and transportation information.
The organization should have documented procedures to prevent shipment of products that have not passed through the release process. Releasing process shall be conducted by qualified personnel having received supply chain security training.

SOLAR WAFER
Poly-Si inputs for production of monocrystalline silicon wafers destined for use in solar modules should be delivered in designated and uniquely identifiable shipping units, e.g., lot or batch number. The logistics documents associated with each shipping unit should preserve the upstream provenance of the input material and that information should be linked to the output product.

The manufacturing processes of solar wafers should include, when necessary, rigorous controls to prevent mixing of input poly-Si from different sources. Additionally, there may need to be rigorous controls to prevent mixing of intermediate products on the production floor. Each intermediate product generated during solar wafer production should be tracked with a Manufacturing Execution System (MES) that can link each intermediate product to its parent product and resulting product(s).

Solar wafer output material should be boxed in defined and easy to handle amounts, e.g., 100 wafers per box. Each shipping unit above should have a unique serial number that can be used to trace the input poly-Si material.

Where material inputs from different sources are mixed or blended together, the manufacturing process should include rigorous controls to maintain provenance, e.g., the source of both inputs travels across the supply chain. Each intermediate product generated during solar cell production, should be tracked with a Manufacturing Execution System (MES) that can link each intermediate product to its parent product and resulting product.

Solar cell output material should be boxed in defined and easy to handle amounts, e.g., 100 wafers per box. Boxes of cell may be combined into larger boxes which are then combined on a pallet. Each shipping unit should have a unique identifier, e.g., unique box number, that can be used to trace the input solar wafer material. When necessary, manufacturers should also maintain an auditable process for keeping material from different sources physically separated at each intermediate step in the solar cell manufacturing process.

SOLAR MODULE
Solar cell inputs for production of solar modules should be delivered in designated, serialized shipping units. The logistics documents associated with each shipping unit should preserve the upstream provenance of the input material and that information should be linked to the output product.

The manufacturing processes of solar modules should include rigorous controls to prevent mixing of input cells from different sources. Additionally, there must be rigorous controls to prevent mixing of intermediate products on the production floor. Each intermediate product generated during solar module production should be tracked with a Manufacturing Execution System (MES) that can link each intermediate product to its parent product(s) and resulting product(s).

Solar module outputs should be palletized in defined amounts, e.g., 20-30 modules per pallet. Each pallet should have a unique serial number that can be used to trace the input solar cell material.

ANNEX B: GUIDANCE ON RISK MANAGEMENT RISK FACTORS
Supply chain risks can be associated with the following:

RISK MANAGEMENT PROCESS
Risk management processes shall follow an improvement cycle based on the inputs gathered.

RISK IDENTIFICATION
In the risk identification phase, the organization should create an objective list of the risks taking into consideration a variety of factors, such as the nature of risk and changes in risk profile. The organization may use different techniques such as interviews, surveys, and auditing to increase reliability in the characterizations of the risk.

IMPLEMENTATION OF THE DUE DILIGENCE PROGRAM
OVERVIEW OF DUE DILIGENCE PROCESS
The implementation of the due diligence process will consist of the repetition of individual due diligence activities, combined and summarized to provide an overview of the whole supply chain in the scope of the due diligence program.

INITIATING DUE DILIGENCE ACTIVITY
The audit team should first establish a dialogue with the organization’s compliance department and confirm communication channels, including:
• Confirm authority to conduct due diligence activity;
• Provide relevant information on the due diligence process (e.g., scope, criteria, methods, teams, schedule);
• Request access to relevant information to conduct due diligence activity;
• Determine applicable statutory and regulatory requirements;
• Confirm management and treatment of information, especially the management of confidentiality;
• Confirm arrangements including schedule, access, health and safety, and security;
• Confirm attendance of observers where applicable;
• Determine relevant areas of interest or concern with the organization subjected to due diligence activity

NONCONFORMITY MANAGEMENT
In this section, nonconformity refers to findings identified during the due diligence process or to a nonconformity arising from the process itself. Nonconformity arising from the process itself may include:
• Failure to perform due diligence as agreed;
• Unresolved diverging opinions on the outcome of the due diligence process;
• Reported Impartiality or ethical issues occurring during due diligence;
• Competences issues identified during the diligence process; and • Breach of confidentiality or information security occurring the due diligence process.
The organization should establish a process, including reporting, investigating, and taking actions to determine and manage nonconformities. When a nonconformity occurs during due diligence, the organization should as applicable:
• React timely to control the nonconformity;
• Take actions as applicable to correct the nonconformity and deal with the consequence; and
• Take actions to prevent reoccurrence of the nonconformity.

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